The decedent was the sole beneficiary of a marital trust created under her husband’s will. The marital trust contained interests in four limited partnerships that were subject to a Buy-Sell Agreement. The decedent established a testamentary charitable lead trust.

Following the decedent’s death, the trustees of the testamentary charitable lead trust inherited a percentage of the marital trust’s limited partnerships from the decedent. The Buy-Sell Agreement, which came into effect upon the bequest, required the executor to sell to the limited partnership the limited partnership interests.